LATE RFI Response to Information Request

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PO9 of District Centre Zone Code also seeks that at the edges of the District Centre zone lower
… intensity business and community uses will form a transition to residential uses.
The carwash is proposed to serve a much broader area than intended by the Strategic Outcome
for the area, serving the Noosa hinterland and is not considered a low intensity business or
community use with the applicant’s design expert estimating the car wash will provide for about
68,000 car washes per year, based on the trade area, which is a substantial number, with the
proposed carwash to operate 24 hours.

Information Required

1. Provide comment/analysis demonstrating why strategic outcome 3.3.5 (s) (ii) (G) and the
   District Centre zoning intent should be set aside. The response is to include comment on the
   availability of appropriately zoned land to meet the current and future needs of residents on
   the eastern side of Cooroy.

2. Provide comment/analysis demonstrating how the proposed carwash meets PO9 of the
   District Centre Zone Code and will assist in forming a transition to nearby residential uses.
   This should include a comparison with other uses identified as consistent for the site.

Comment:

The request for further information raises the potential inconsistency with the following
provision under the Strategic Framework, strategic outcome 3.3.5(s)(ii)(G), which states:

Cooroy is divided by the railway line with the concentration of the centre activities located on
the western side. The eastern side retains its service role to support the district centre by providing
small-scale, local convenience goods and services for nearby residents, which may include a
small-scale supermarket provided the need can be economically justified. (emphasis added)

Further, performance outcome PO9 of the District Centre Zone Code, states:

Development respects the fact that higher intensity retail uses are concentrated in traditional
core main streets and that at the edges of the District Centre Zone lower intensity business and
community uses form a transition to residential uses.

In relation to the issues raised, further advice has been obtained from the applicant’s economic
expert, which is provided as Attachment 2.

The economic expert has addressed about the following issues:
   • the role and function of the District Centre in Cooroy;
   • how a commercial carwash serves the local community;
   • the role of industrial areas;
   • the function of the eastern part of the District Centre in Cooroy; and
   • the remaining capacity of the District Centre.

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It is stated in the further advice that the trade area identified is generally consistent with what
would be the practical trade area for the Cooroy District Centre, which extends beyond the
Noosa local government boundary and includes Pomona as a secondary trade area. There is
no carwash in the Noosa Hinterland, with the closest carwash locations being in Noosaville
and Gympie.

Given the location and high level of accessibility provided by the site, it would be reasonably
expected that tourists and residents would frequent the proposed carwash when attending
and passing through Cooroy. This would include residents from the surrounding hinterland
areas using the connection roads from Pomona to Cooroy, either passing the site via Elm Street
(or driving close to it) and using Diamond Street which joins with the Cooroy-Noosa Road.
Further, tourists and other travellers that visit Cooroy from the Bruce highway would use Mayall
Street and Elm Street passing the site and ultimately travelling to Noosa using Diamond Street
and the Noosa-Cooroy Road. It is not expected that the carwash itself would be a destination
point necessarily, but residents and tourists alike could attend the carwash when passing the
site, given the location on a major connector road. This is the same scenario for residents and
tourists utilising the two existing service stations in this location, as reasonably expected.

It is noted that Strategic Outcome 3.3.5(F), states:

Cooroy District Centre serves as the main activity centre for the communities of Cooroy and other
outlying hinterland villages. Cooroy has a strong historic country town identity with a number
of local and state listed heritage buildings. The centre provides services to rural enterprises in the
surrounding hinterland area. ….” (emphasis added)

It is expected that development located within the Cooroy District Centre will service the trade
area that has been identified, which includes the Noosa Hinterland (and including Cooran). I
agree with Mr Brown that while the eastern side of the Cooroy Township forms part of the
District Centre it contains businesses, such as the “Sauers Produce and Garden Centre”, which
serve a broader catchment, in a similar manner to the proposed carwash. The eastern side of
the District Centre also contains the only two service stations in the Cooroy locality and would
also be expected to serve residents and tourists. The service stations, like the proposed
carwash, are well located for these car orientated uses and facilities being on a major collector
road (Elm Street).

Having regard to the strategic outcomes above, it is also reasonably expected that a small
scale supermarket would be provided within the District Centre on the eastern side of Cooroy.
It is noted there is a current development approval (MCU19-0001) for a local convenience
store and shops fronting the main street at 6-10 Diamond Street, Cooroy approved in 2020,
and having a currency for six (6) years. Consequently, outcome 3.3.5(s)(ii)(G) is potentially
satisfied (at least in part), without the need for the subject land. This is in terms of the provision
of a small supermarket that would provide local convenience goods on the eastern side of
Cooroy. Further, it is suggested that if a small scale convenience supermarket is to be located

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on the eastern side of the District Centre, it should be located within Diamond Street, this
being the main street for the eastern centre area, having a highest level of activity, and being
more pedestrian orientated, with a consistent built form being established.

As stated by Mr Brown (and referred to in the town planning report for the application), the
subject site has a development approval for a number of shops (MCU18/0158), which was
granted on 9 August 2019, and remains current for 6 years. It is evident that, despite the
approval, there was little demand for additional shops in this location, with the site being sold
to the applicant due to a lack of interest in taking the development further.

Mr Brown has also addressed the available land within the District Centre Zone to the east,
that is potentially available for future development to meet the needs of the local community.
This includes at least six (6) properties that contain houses and ultimately will be developed
for commercial purposes in the long term, including two (2) sites that are about 1,000m², which
are grossly underutilised.

Another issue that has been raised under performance outcome PO9 above, is that the site is
not located with the traditional core main street, which is Diamond Street, and rather is on the
fringe of the District Centre, where lower intensity businesses are expected, to provide a
transition to the residential areas behind. In this case, the proposed carwash is located between
two service stations, with a service station also being an inconsistent use within the District
Centre Zone. A service station also performs a similar business-to-household function, which
is discussed below.

The site is also located adjacent to a non-residential use, which is now operated as a “Your
Mates BowlsPub”. The proposed commercial carwash in this location will complement the
existing service station uses and will not cause significant adverse impacts on nearby
residential properties. This is in terms of the noise generated and any traffic impacts, and as
explained by Mr Curtis below, will not be out of character.

The key issue associated with the proposal is that under the Noosa Plan 2020, a carwash is
technically defined as an industrial use making it an inconsistent use within the District Centre
Zone. Despite this, and as stated in the town planning report, there are a number of relevant
matters to be considered, which favour approval, given the proposed development will have
no town planning consequences.

As stated in the further advice provided by Mr Brown (Attachment 2), carwashes service a
local community, with modern carwashes providing a service to households. The primary use
of carwashes is for the washing of private vehicles, which represent the bulk of the demand,
as opposed to washing the family car at home, which is less sustainable.

As Mr Brown has explained, a carwash is a business-to-household transaction1, which is the
most common transaction found in centre locations, which generally have a high level of

1
    Advice from Bull + Bear, page 2

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accessibility, which is the case here. From a town planning perspective, the establishment of
these types of uses within an industrial location is not desirable, given industrial uses are
primarily concerned with business-to-business transactions2 synonymous with development
within an industrial estate, such as in Cooroy. This is different from centre uses that are typically
household-to-business transactions, and consistent with uses expected to be located within
the District Centre, and in this case, similar to a service station3.

I agree with Mr Brown that Noosa has a limited amount of urban land, which underpins the
balance sought to be achieved in terms of providing sustainable development and maintaining
the environmental values and the character and amenity of the area. Further, not all industrial
locations are the same. For example, the Noosaville Industrial estate adjoins the Eumundi-
Noosa Road (a higher order road) and is effectively a mixed use area, including service stations,
the Noosa Car Spa (commercial carwash) and other hardware/showroom uses. Many of the
uses fronting Eumundi-Noosa Road are of a commercial rather than an industrial nature. Not
surprisingly, the Eumundi-Noosa Road has a high level of accessibility and passing trade,
similar to the subject site, making it desirable for a commercial carwash and service stations,
which are relatively new developments in this location.

The industrial land in Cooroy is in two separate locations, which are purpose destinations, and
not readily accessible by day-to-day traffic or passing trade and therefore not desirable for a
commercial carwash. From a town planning perspective, it is desirable for valuable industrial
land to be used for an industrial purpose (business-to-business), including businesses that
operate as wholesalers, manufacturers, and transporters of goods, which provide economic
benefits, including employment.

Locating a carwash within an industrial area, will result in the use of land by a business-to-
household use at the expense of business-to-business enterprises, the core business group
industrial areas are intended to accommodate4. In my opinion, the available land within the
industrial estates, which is limited, would be better utilised for an industrial purpose rather
than for a commercial carwash, given the identified economic, community and planning need
for a carwash in the Cooroy locality.

I agree with Mr Brown that while commercial business owners will use the carwash, they will
be in the minority. The location of a commercial carwash within the industrial estates in Cooroy,
also risks compromising the function of industrial land, with increased non-industrial related
traffic being generated, in circumstances, where a carwash is heavily reliant on passing trade5.
The proposed location within Cooroy is similar to that in Noosaville, being on a higher order
collector road, providing for passing trade having good accessibility, and located between two
service stations.



2
  Advice from Bull + Bear, page 2
3
  Forms part of the Business Activity Group under Schedule 1 but is an inconsistent use under Table 5.5.6
4
  Advice from Bull + Bear, page 3
5
  Advice from Bull + Bear, page 2

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With respect to the specific questions that have been asked under this part of the information
request, in summary:

1. Having regard to part 3.3.5(s)(ii)(G) under the Strategic Framework, it is not necessarily the
   case that the land being occupied by the proposed carwash is not meeting the intent of
   the District Centre Zone, given the nature of the use. While the use is technically defined
   as an industrial activity under Schedule 1, as explained by Mr Brown, the use provides a
   business-to-household function, which is consistent with other uses expected within the
   District Centre. Further, provides for a much needed service for the local community and
   visitors, which is currently not able available within Cooroy and the Noosa Hinterland.

    Mr Brown has also explained that the expected trade area for the carwash is consistent
    with part 3.3.5(s)(ii)(F), with the District Centre intended to service the communities of
    Cooroy and the Noosa Hinterland, as is the case for other businesses within this part of
    the District Centre. It has also been explained there are a number of properties within the
    eastern area of the District Centre which are currently underutilised. Further, there remains
    a current development approval for a small convenience store and other shops in Diamond
    Street (yet to be developed), with no interest being expressed in developing the subject
    site for shops under a current development approval.

2. With respect to the use of the site to provide a transition to nearby residential uses, the
   use of the land for a commercial carwash is compatible with the adjoining service stations
   on either side, which can’t be ignored. Each of these service stations could contain an
   ancillary carwash component and are also uses that are inconsistent within the District
   Centre Zone. Further, the site adjoins the bowls club to the east and is otherwise isolated,
   having three (3) road frontages. The site is removed from residential properties and
   according to the Environment Noise Assessment provided with the application
   (Attachment 5), will not have an adverse impact on the amenity of nearby residential
   properties. The proposed development will provide a suitable transition in this location,
   being a compatible use that is in keeping with the character and amenity of the area.

Issue – Design

The Cooroy Local Plan Code seeks that development in the town centre maintains and
complements the traditional built form, addresses the street, provides, and maintains small,
typical narrow tenancies with intimate continuous weather protected footpaths and active
frontages. Roof forms use traditional Queensland style roof designs and buildings reflect the
traditional Queensland vernacular and incorporate lightweight materials such as timber.

The Cooroy Local Plan code further identifies the site as being a Key Development site with
development having the potential to impact on the character of the centre.

PO22 of the District Centre Zone Code details that buildings and other structures are to present
a high quality streetscape with design elements and building forms that:

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    a) define the street and public spaces;
    b) provide a consistent awning alignment fronting the street and public spaces;
    c) contribute to the streetscape activity and vibrancy of the centre;
    d) create pedestrian scale and visual interest;
    e) contribute to their setting, including the skyline;
    f) celebrate corner sites as key focal points that contribute positively to defining the street;
       and
    g) provide areas outdoor dining and meeting opportunities on the ground level.

The outcomes further detail that development is to make a positive contribution to the
streetscape and maintain a shop front presence to the street with uses designed to activate
frontages and provide access to the general public required.
The proposed industrial use is not considered to comply with the Outcomes of the Cooroy Local
Plan Code and District Centre Zone Code due to the extensive vehicle manoeuvring areas visible
to the street, limited street activation and awning.

Information Required

3. Revise the plans to provide a simpler, consistent roof form across the central building and
   provide some articulation, and treatment to improve the eastern elevation’s presentation
   having regard to the design and built form requirements for Cooroy.

4. Demonstrate how the proposal addresses the outcomes of the Cooroy Local Plan Code and
   District Centre Zone Code with reference to street activation, awnings, amenity, character
   and contribution to the streetscape.

With respect to the building design issues raised, the applicant has sought advice from a
specialist architect and visual amenity expert, which is provided as Attachment 3. The visual
amenity and architectural expert has suggested a number of changes to the design of the
development, which generally include:

    •    the roof pitching presenting to Elm Street being reduced with a corresponding
         reduction in height along with other roof changes, including additional eaves and
         feature and colour pallet changes to improve the overall presentation to the street;
    •    a flat roof provided over the entry to the wash bays and the small office and storage
         area on the southern side;
    •    the roof pitch for the small takeaway building has been reversed, full height glass doors
         provided, provision of a batten fascia and other colour changes provided to the Opal
         Street frontage to improve the street presentation; and
    •    the roof over the main wash bays has been changed to a low pitch gable, with the pitch
         also being reversed.

While the site is designated as a key development site under the Cooroy Framework &
Character Plan (Figure 7.2.2.4), this is related to the former Cooroy Motel, which was removed

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some time ago. Despite this, it is acknowledged the site is a designated key development site,
which is to incorporate a high standard of architectural design and landscape treatment
consistent with the streetscape character; however, this needs to be considered while having
regard to the context of the site. Mr Curtis advises that … the proposed development is
responsive to the actual context with respect to its existing identity and use. It will improve the
character of the town centre having regard to these well-established neighbouring uses.6

While it is acknowledged the development is for a commercial carwash, it is located between
two existing service stations, which have an industrial nature and character. Consequently, as
explained by Mr Curtis, the development needs to be considered in this context. It is suggested
the proposed use is not out of context and has design elements that respect the country town
feel and will be largely consistent with the existing built form character of the location. The
development will have a different building form but provides for a vehicle orientated
environment consistent with the adjoining uses and within the context of this site, which is not
an intact commercial setting.

In terms of the bulk and scale, Mr Curtis advises that the … overall building bulk is distributed
across the site in three structures that have a low rise scale consistent with the existing
neighbouring service stations and the Cooroy Station opposite. Notwithstanding this consistency,
the height of the tallest structure is mitigated by the varied stepped roofs forms that provide a
gradation of height down to the street frontage.7

With respect to consistency with the character and amenity of the area, Mr Curtis also advises
that based on his observations … the proposed development, while a contemporary building,
maintains and complements the traditional built form. The roof forms, awnings and detailing
are all consistent as a valid interpretation of the traditional vernacular character without
adopting a contrived imagery. Further, the … proposal will provide activation to the adjoining
footpaths and includes an awning along the frontage with shade sails on the corner. 8

I agree with Mr Curtis that when having regard to the neighbouring service stations on either
side, which do not provide footpath awnings, there would be little material benefit in providing
a continuous awning along the frontage of the site. It is expected that such awnings provide
benefit within ‘main street’ environments, which is not the case here, which is a vehicle focused
environment. Further, Mr Curtis advises … the appearance of the built form including the
projecting awnings and largely open sided facades reflect a ‘light weight’ building typology while
optimising the proposal’s functionality and sustainability. 9

In conclusion, I agree with Mr Curtis that:




6
  Visual Assessment Statement, para 95
7
  Visual Assessment Statement, para 75
8
  Visual Assessment Statement, para 91 & 92
9
  Visual Assessment Statement, para 93 & 94

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       a) The proposed development will be consistent with the general character of the existing
          development along Elm Street and is consistent with the existing vehicle dominated
          uses of the two adjoining service stations.
       b) The built form has been carefully considered in its design to reflect the ‘character’
          influences with respect to the primary roof forms and the architectural detailing.
       c) In this location the proposed development will complement the existing streetscape
          and there will be no apparent adverse residual impacts upon local character.
       d) The proposed development is consistent with the intent of the applicable planning
          scheme provisions with respect to the character and amenity outcomes being sought
          having regard to the nature of the use in this setting10.

Issue – Length of Wall

AO21.2 of the District Centre Zone Code details that elevations are not to be longer than 15
metres without articulation. The proposed wall along the eastern boundary provides an elevation
of approximately 19 metres in length and over 7 metres high along the proposed pathway. Whilst
it is noted that this elevation is to be painted with a mural, additional change in texture and
materials is to be detailed to ensure the wall presents appropriately at all times.

Information Required

5. Provide amended plans detailing additional changes in texture and materials along the
   eastern wall to the pathway.

While the length of wall facing the eastern boundary cannot be reduced in length given it
provides for the super wash bays, it is located away from the road frontages and is not
excessive being about 17m in length.

It is intended to treat this wall with a historic mural that would face the bowling green to the
east and adjoins the public pathway. The mural is yet be designed but is intended to relate to
the history of Cooroy and will be able to be viewed and read by the general public using the
pathway and people using the bowling green to the east.

Given the location of this wall, which faces eastwards, it is suggested the addition of the historic
mural will activate this space and will be of interest to the local community. Further, will not
present as a blank space to public spaces and the adjoining land. Other treatments could be
provided to this wall, if necessary, which is a matter that could be conditioned.

Issue – Street Trees in Opal Street

There is existing vegetation in the Opal Street road reserve which the proposed works appear to
adversely impact on.


10
     Visual Assessment Statement, para 99

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Information Required

6. Provide amended plans retaining the existing street trees in Opal Street or provide details
   demonstrating why these trees should be removed.

The proposed carwash provides for access off Opal Street and egress off a widened Opal Lane.
The access off Opal Street is required to be provided in this location to facilitate the required
access into the site, which will cater for cars towing a caravan or boat and using the super wash
bays. Further, the proposed access allows for the small food and drink outlet and improved on
street parking, which was discussed with Council officers previously, and will benefit the local
community.

The proposed access necessitates the removal of a single street tree in Opal Street; however,
it is proposed to plant an advanced pot size tree on the eastern side of the driveway, as shown
on the amended Landscape Concept Plan provided as Attachment 4. The other two (2) street
trees in Opal Street to the west are being retained. The applicant would accept a condition
nominating the particular tree species to be provided in Opal Street, having an advanced size.

The plant species shown on the Landscape Concept Plan are indicative only at this stage, given
a further development approval for operational works is required, which will provide a greater
amount of detail. It is also noted that the four (4) street trees in Opal Lane are to be replaced,
which are required to be removed to allow for the road widening in this location, as required
by Council.

Issue – Carparking

The proposed car parking is not consistent with the car parking rate for a carwash under The
Noosa Plan 2020 and in part relies on street car parking. A more accessible parking space should
also be provided for the proposed dog wash bays.

Information Required

7. Provide amended plans providing additional onsite car parking to meet the Driveways and
   Parking code minimum rate, having regard to accessibility for users.

Reference is made to the further advice provided by Traffic and Transport Plus, which
addresses the matter of onsite parking and the available sightlines in Opal Street (refer
Attachment 5).

Under the Driveways and Parking Code, performance outcome PO6, states … sufficient parking:

a) is to be provided having regard to the specifics of the land use, including:
   i. the type and intensity of land use;
   ii. any existing parking available on the site;

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       iii. hours of operation;
       iv. likely numbers of users;
       v. accessibility to the site by means other than private
       vi. motor vehicle;
       vii. the peak parking demand periods of uses on the
       viii. site; and
       ix. the availability of alternative car parking; and

b) is provided to accommodate the number and type of vehicles and motorcycles likely to be
   generated by the development.

Under acceptable outcome AO6, which refers to Table 9.4.1.4, the minimum amount of parking
required for a carwash is one space for 50m² up to 500m² of the gross floor area (GFA) and
one space per 100m² in excess of 500m².

Given the nature of the use, a commercial carwash by its nature has very little GFA when having
regard to the administration definition under Schedule 1. This is because the definition of GFA
excludes building services and plant, and areas for parking, loading, or manoeuvring of
vehicles. Consequently, the proposed carwash has very little, if any GFA, with one space to be
provided for the onsite manager.

Under Table 9.4.1.4, for a Food and drink outlet, the applicable parking rate is one space per
20m² of use area, which excludes the kitchen and food storage areas. The proposed Food and
drink outlet provides for a small amount of GFA this being about 31.5m², which contains the
kitchen, serving area and food storage. Consequently, the actual built from for the food and
drink outlet does not trigger a requirement for onsite parking. The development does however
provide for a small outdoor seating area comprising about 30.0m², which is use area, and
therefore requires two (2) spaces. Two (2) parking spaces have been provided near this use to
the south of the carwash building.

Importantly, the amount of queuing space available on the site for the carwash is substantial,
with provision for 26 vehicles, as shown on the General Layout Plan and also referred to in the
Traffic Impact Assessment, dated 27 October 2022. This includes the six (6) parking spaces
within the carwash bays and queuing spaces within the entry lanes to the wash bays. Further,
the development provides onsite parking for each of the vacuum and dog wash bays. A total
of three (3) parking spaces are technically required and have been provided.

The traffic expert has also considered the parking requirements for a commercial carwash
under other SEQ planning schemes for comparison purposes. This exercise has revealed that
providing zero or one (1) parking space for the proposed carwash would accord with these
planning schemes11. The traffic expert has also considered the additional car parking already
available and to be provided within Opal Street, which is a relevant matter. It is noted that the
availability of alternative carparking forms part of performance outcome PO6 (refer part (vii)).

11
     Response by Traffic and Transport Plus, dated 6 June 2023, paras 8, 9 & 10

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It is evident from the above, that the proposed development complies with the planning
scheme in terms of the number of carparks to be provided; however, in a practical sense,
patrons of the small food and drink outlet will likely utilise the additional on street parking to
be provided in Opal Street. It is noted the traffic expert has advised the expected dwell times
within these bays will not be high. Further, Opal Street is far from a “tipping point” when it
comes to on street parking and the proposed food and drink outlet would have negligible
impact on the on street parking in this location12.

Having regard to the advice provided by the traffic expert, adequate onsite parking and
queuing is available and the proposed carwash will not cause significant offsite traffic impacts.
The development also provides two (2) super bays providing carwash facilities for people with
caravans and boats, including tourists, which is a facility not currently available in the Noosa
area. Given tourists and local residents alike will utilise the facility, the development will provide
significant economic and community benefits. The proposed development complies with the
Parking and Driveways Code.

Issue – Stormwater Design

Council has a number of queries with regard to the preliminary stormwater design plans
including:
i. Is the design engineer a Registered Professional Engineer of Queensland?
ii. Does the design include consideration for climate change?
iii. The rainfall intensities do not appear to be site specific (Cooroy locality)?
iv. The proposal includes a proprietary device to treat stormwater runoff. Council’s preference is
     for natural processes?
v. The design includes a connection to Council’s system in Opal Street but no detail on the
     structure has been indicated?
vi. The design does not include any levels and does not demonstrate that the system will function
     or demonstrate that it will not conflict with other buried services in the road reserve?

Information Required

8. Provide additional comment and/or plan amendments to address the following:
   8.1. Is the design engineer a Registered Professional Engineer of Queensland?
   8.2. Provide additional comment and/or amended plans regarding the design consideration
        for climate change. The additional detail must demonstrate that the design achieves
        compliance with The Noosa Plan 2020 – Water Quality and Drainage Code – PO2 and
        AO2.4 (20% increase in rainfall)
   8.3. Provide amended calculations that utilise rainfall data for the subject site area (Cooroy
        Locality)
   8.4. Provide additional detail/comment to demonstrate that the design achieves compliance
        with The Noosa Plan 2020 – Water Quality and Drainage Code – PO7 and AO7.1

12
     Response by Traffic and Transport Plus, dated 6 June 2023, para 17

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       8.5. Indicate on the design the structure proposed to be constructed to connect to Council’s
            system in Opal Street
       8.6. Provide amended plans that includes additional detail (levels etc) that is sufficient to
            demonstrate that the system will function and will not conflict with other buried services
            in the road reserve.

The design consultant has provided an updated Holistic Stormwater & Waste Water
Management Plan (SWMP), which has been certified by CMG Consulting Engineers (refer
Attachment 6). The applicants design consultant has met with Mr Lewis, Coordinator
Engineering, Development Services to explain the need to provide a propriety stormwater
drainage system on the site given the minimal amount of fall and for the site to effectively
drain to existing infrastructure in Opal Street. It is my understanding that the SWMP and the
proposal plans collectively address the issues raised above.

The proposed SWMP provides a complete analogy of how the proposed carwash can benefit
the local environment and reduce the current discharge of polluted stormwater including
reducing the volume of pollutants entering local waterways by 48%, based on the current car
washing practices of the primary and secondary trade areas. The proposed design will result
in the harvesting of approximately 96% of annual rainfall events for total re-use within the
washing process. Further, reduces the demand on local mains water by over 1.1 ML per year
(based on the 50% rainfall annual total).

Because of the large, roofed area contributing to rainwater harvesting, this reduces the
contributing site area that yields rainfall run-off in a design storm event. This ensures the
proposed carwash will reduce the volume and peak flow rates of the stormwater site discharge
when compared to the discharge from the pre-developed site.

The proposed stormwater quality treatment train consists of SQIDEP approved products and
exceeds the minimum stormwater quality improvement targets. A commercial contract could
be entered into to ensure the proposed stormwater drainage system is regularly maintained.

I agree with the design consultant that it is widely accepted that a commercial carwash is an
environmentally friendly and responsible, convenient, cost-effective method of washing a
vehicle or dog. The proposed development will provide significant environmental and
community benefits in the long term and will not have any negative effects on the local
infrastructure13.

Issue – Sight Lines

The proposed on-street parking spaces are closer to the intersection than a previous approval for
the subject site. Council has concerns that the existing services (poles, phone box) and existing
and proposed vegetation will impact on the available sight lines.


13
     Stormwater Management Plan, part 7

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Information Required

9. Provide additional comment from the traffic engineer that addresses the potential for existing
   services (poles, phone box) and existing/proposed vegetation to impact on the available sight
   lines. The comment must also include recommendations for any necessary works to provide
   the required sight lines.

The sightlines for the proposed parking spaces in Opal Street have been considered by the
traffic consultant (refer Attachment 5).

In summary, the traffic consultant has advised that if the vehicles entering Opal Street from
the western end are obscured by drivers parked in the western most space, this would only
occur briefly, and the cars would be visible in the moments immediately before and after the
moment in which they are obscured. This obscuration only occurs when a vehicle turning right
into Opal Street is stationery and a vehicle stopped in the western space reverses onto Opal
Street, that is when a vehicle leaves the western bay. Importantly, any vehicle located in blind
spots caused by the obstructions become visible before the car has reversed into the trafficable
part of the eastbound lane. Further, night time vehicles entering Opal Street from Elm Street
would have their headlights lit and would be more visible to vehicles reversing from the
western space14.

The traffic consultant has also recommended that a road line be painted on the northern side
of Opal Street, extending from the kerb on the north east corner eastwards towards the
proposed access. The painted line will encourage eastbound vehicles on Opal Street to remain
close the centreline and ensure vehicles reversing from the proposed on-street parking spaces
adjacent to the subject site are able to view vehicles on Opal Street and stop appropriately to
give way, as required15.

Having regard to the advice provided by the traffic consultant, adequate sightlines are
afforded for a vehicle using the new on street parking spaces in Opal Street. The addition of
the painted line as suggested will assist with forcing cars closer to the centre line, which will
increase the separation distance from a car using the on street carparks and cars entering Opal
Street. This is a requirement that could be conditioned.

Issue – Footpaths

The layout plan does not provide sufficient detail on the proposed external works. It is noted that
Elm Street is a DTMR road but Council’s expectation is that footpaths in both Elm Street and Opal
Street will be required to be upgraded to 2m wide footpaths.

Information Required


14
     Advice from Traffic and Transport Plus, paras 26-28
15
     Advice from Traffic and Transport Plus, paras 29

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10. Indicate on the relevant plans that the external footpaths are to be upgraded to 2m wide
    paths.

With respect to the above issue, the updated proposal plans provide for 2m wide footpaths
along the Elm Street and Opal Street frontages (refer Attachment 1). Further, extend to the
frontage of the new carparks to be provided in Opal Street, with the existing street tree in this
location to be maintained. Further, the 2m wide footpath extends to the eastern side of the
egress from Opal Street and long the proposed new pedestrian walkway along the eastern
boundary as intended under the Cooroy Framework & Character Plan (Figure 7.2.2.4).

Development Assessment Rules

In accordance with section 13 of the Development Assessment Rules, the applicant has
responded to the information request. The applicant will begin public notification within 20
business days in accordance with section 16.3. Please provide the adjoining owners’ details as
soon as possible.

Should you require further information please contact me.

Yours faithfully


Shane Adamson
Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd




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